Subject Matter of the Terms and Conditions of Use

This agreement concerning the Terms and Conditions of Use of Website www.copersucar.com.br (“Terms of Use”), seeks to govern the use of the website http://www.copersucar.com.br (“website”), created by Copersucar S/A (“Copersucar”), and pertains to the use of the website in all its areas, whether open and readily accessible or those whose access is restricted.

These Terms of Use may be amended or updated unilaterally and at any time by Copersucar, whenever new resources or functionalities are added to the website or whenever Copersucar, at its sole discretion, deems necessary.

The amendments to the Terms of Use will become effective on the date on which they are published on the website, and Copersucar shall post and maintain, at the top of the Terms of Use page, a notice reporting the updates made to the Terms of Use for at least 30 (thirty) days of the date on which such update is published.

Acceptance of the Rules for Use of the Website

When accessing the website, users, which shall be construed as any individual or legal entity accessing or using the website via any means (“User”), agrees to and accepts the terms of these Terms of Use.

Users who do not agree to these Terms of Use should not use the website.

Since these Terms of Use may be updated, Users should review these Terms of Use periodically. The use of the website after any eventual update to these Terms of Use shall be deemed to be acceptance of the updated Terms of Use by Users.

Purpose of the Website and Changes to Contents

All content of the website is offered to people aged 18 (eighteen) or older or to minors authorized by their parents or guardians. Copersucar reserves the right to assume that website Users meet the requirements above.

Copersucar may change the format and contents of the entire website at any time, as well as discontinue its operation and restrict or terminate access to the website at any time, regardless of prior notice to Users.

Intellectual Property

The content of the website, including text, images, sound, software, and codes that compose and operate this website, is protected by copyright and/or other intellectual property rights of Copersucar or licensed to Copersucar by their rightful owners.

Likewise, all trademarks or service trademarks included on the site are property of Copersucar or have been licensed to Copersucar by their rightful owners for use on this website.

Copy, distribution, or change, in any form, of the contents of this website or the use of the material contained on the website in any way other than presented therein is strictly forbidden. Moreover, the removal of any identification pertaining to copyright, trademarks, or intellectual property contained on the website is strictly forbidden.

The use of any of the brands displayed on the website must have express prior written consent of Copersucar or of the owner of such trademark.

Links to Third-party Websites

The website may contain links to third-party websites and Copersucar shall not be held liable for any analysis, assessment, or content of such third-party websites, and Users shall be responsible for evaluating browsing and content of each such websites exclusively.

Data Protection / Privacy Policy

The protection of Users’ personal information when using this website is set out in Copersucar’s Privacy Policy , which is part of and incorporated into these Terms of Use.

Responsibilities

Users are solely liable for the use they make of all contents, products and services made available through the website.

Copersucar hereby attests that the information on the website is generic in nature and should not be taken separately as basis of decision-making.

Copersucar uses its best efforts so that the content of the information on the website is accurate and corresponds to reality at the moment it is published on the website; nevertheless, Copersucar makes no claims to Users concerning its accuracy.

Under no circumstances shall Copersucar, its affiliates, directors, or services providers be held liable for indirect, incidental or consequential damages or loss of revenue arising out of the use of the website, of information published on the website, or of the impossibility of access to the website.

Any eventual compensation, limited to the duly substantiated direct damages, shall only be owed whenever the damage caused by Copersucar to Users is duly substantiated, and any eventual exceptions are not set forth in these Terms of Use.

Binding of the Parties

Failure to exercise or enforce any rights or provision of these Terms of Use shall not constitute a waiver of such right or provision, unless such waiver is made in writing by Copersucar’s legal representatives.

Should any provision of these Terms of Use be considered, by the competent court, to be unlawful, such provisions shall be amended and construed so as to meet the objectives of the original provision, to the extent possible and to the full extent of the law, and all other provisions of these Terms of Use shall remain in full force and effect.

Governing Law

These Terms of Use are governed by Brazilian law and any inconsistencies or conflicts not solved out of court shall be settled in the jurisdiction and venue of any court of the city of São Paulo/SP, to the exclusion of all others, regardless how privileged.

Information or Questions about these Terms of Use

All questions concerning these Terms of Use should be sent to the email comunicacao@copersucar.com.br.

In effect commencing November 26, 2020.

1 What are cookies and other similar technologies?

2 How does Copersucar use cookies?

3 How to manage your cookie preferences

4 Updates to this policy

5 How to get in touch with us

Hi and welcome to the Copersucar cookie policy.

The purpose of this policy is to provide you, the user of the Copersucar website, with clear and accessible information about cookies and the role they play in improving the browsing of our content, in addition to the options for configuring them.

1. What are cookies and other similar technologies?

Cookies are text files downloaded on your device when you visit a site. They are useful for allowing a site to recognize the user’s device. You will find more information about cookies at: www.youronlinechoices.eu or www.allaboutcookies.org.

The term cookie actually describes a series of technologies, including:

pixel tags (transparent graphic images placed on a web page or in an e-mail to indicated they were viewed),

mobile device identifiers, and

storage on the Web used in computer software or on mobile devices.

We will use the cookie throughout this policy to cover all these technologies, but we will provide you with all details about them, so that you can make conscious choices about the configurations of cookies.

Cookies serve several purposes, such as allowing efficient browsing between pages, remembering preferences and, generally speaking, enhancing the user’s experience. They can also help to ensure that the ads you see online are more relevant to you and your interests.

There are several different categories of cookies, including:

Session and persistent cookies

1. Session cookies – are cookies that expire once you close your web browser; and
2. Persistent cookies – are cookies that have to remain on your device for a defined period or until you exclude them.

Proprietary and third-party cookies

1. Proprietary cookies – are cookies defined by the site you are accessing at the time, whether by us, or by a third party on our behalf;
2. Third-party cookies – are cookies defined by a different party from that of the site you are accessing. If you visit the Copersucar site and another party defines a cookie through that site, it will be a third-party cookie.

Cookies also differ according to the purpose they are used for, including:

Type of cookie  Purpose

• Strictly necessary cookies: These cookies are essential so that you can use the resources of our services, like storing the user logged in and active session information. These cookies are essential for supporting the main functionality of the site, such as providing a secure log-in.
• Performance cookies: These cookies collect data about how our visitors browse our site. For example, which pages visitors access most, and whether they receive error messages from Web pages. These cookies collect anonymous data about the pages visited. All data that these cookies collect is aggregated and, therefore, anonymous. They are only used to improve how our services function. Web analysis that uses cookies to gather data and enhance a site’s performance is classified in this category. For example, they can be used for test projects to assure users of a consistent appearance. This category does not include cookies used for behavioral/targeted advertising networks.
• Functionality cookies: These cookies enable a site to memorize the choices you make (like your user name, language or the region where you are located) and provide enhanced and more personal services. These cookies can also remember the changes you made to the text size, fonts and other parts of web pages that you can personalize. The data these cookies collect can be anonymous and cannot control your browsing activities on other sites. These cookies memorize the options you make to improve your experience. If the same cookie is used for redirecting, it should also be included in the “Directing or advertising cookies” category. It must also include cookies used to offer a specific function, but when this function includes cookies used for behavioral/directed advertising networks, it they should also appear in the “Directing or advertising cookies” category.
• Directing of advertising cookies: These cookies are used to provide advertisements that are most relevant to you and your interests. They are also used to limit the number of times you see an advertisement, as well as helping to measure the efficacy of advertising campaigns. They are usually placed on advertising networks with the site operator’s permission. They recall that you accessed a given site, and this data is shared with other organizations, like advertisers. It is very common for directing or advertising cookies to be linked to the functionalities of the site provided by other organizations. These cookies collect data about your browsing habits to make the advertisement relevant for you and your interests.

2. How does Copersucar use cookies?

Copersucar, or our service providers operating on our behalf, use the types of cookies identified in Section 1 above, in the following ways:

Type of cookie  Purpose

Strictly necessary            These cookies are necessary for us to respond to what you asked us for. For example, they allow us to recognize what type of visitor you are and later display data according to your profile, for example, employees and visitors.

Performance/analysis   We use cookies and other similar technologies to analyze how the Copersucar site is accessed or functioning. We use this data to maintain, operate and continuously improve the Copersucar sites. In addition, we can obtain data from our e-mail information bulletins or other notifications we send you, including whether you opened or forwarded an information bulletin or clicked on a content item. This data tells us about the efficacy of the information bulletins and helps us ensure that we are providing information you consider interesting.

Functional          These cookies allow us to operate the Copersucar portal according to your preferences. For example, when you continue using or return to the Copersucar portal we can provide you with our services based on the data provided, such as remembering your user name, how you personalized our services, reminding you about the content you had listened to enjoyed previously.

Targeted advertisements            We use these cookies and other similar technologies to provide advertisements that are relevant to you and your interests, including interest-based advertisements. This data can also be used to record how many times you have received a certain advertisement, and so that we do not repeatedly show the same advertisement, as well as helping us to evaluate its efficacy.

Third-party         We can allow our business partners to use cookies or other similar technologies on or off the Copersucar site for the same purposes identified above, including gathering data about your online activities over time and on different sites, applications and/or devices.

Copersucar advertisements       We work with sire editors, app developers, advertising networks and service providers to provide advertisements and other content that promotes Copersucar on other sites and web services. Cookies and other similar activities can be used to send advertisements that can be relevant to you and your interests on other sites, apps and devices, and to regulate the advertisements you receive and measure their efficacy.

3. How to manage your cookie preferences

Cookie Consent Bar

You can withdraw or amend your consent about the use of cookies at any time. Once you access the Copersucar portal, in the lower right-hand corner a preference bar will be displayed of the cookies that will be gathered, giving you the option of revoking at any time the collection of this data.

Browser cookies

You can withdraw or amend your consent about the use of cookies at any time. If you no longer wish to receive cookies, use the web browser configurations to accept, refuse and exclude cookies. To do this, follow your browser’s instructions (usually within the configurations of “Help”, “Tools” or “Edit”).

If you configure the browser to refuse cookies, you will run the risk of not being able to use all the resources of the Copersucar site. For further information, go to www.allaboutcookies.org.

Mobile device identifiers

On your mobile device, your operating system can provide more options for canceling your interest based on advertisements or, then, redefine your cell phone’s identifiers. For example, you can use the option “Limit advertisement tracking” (only on iOS devices) or the configuration “Cancel interest-based advertisements” (on Android) which enable you to limit the use of data about the use of apps for providing advertisements that target your interests.

4. Updates to this policy

We may amend this policy from time to time.

When we make major changes to this policy, we will provide you with an evident notice, for example, a highly visible signpost on the Copersucar site.

If you wish to know more about the Cookie Policy and how Copersucar uses your personal data, access our Privacy Policy

5. How to contact us

Thanks you for reading our Cookie Policy. If you have any doubts in this regard, contact our data protection representative using the “Contact us” form in the Privacy Policy or write to the following address:

Copersucar S.A.: Avenida das Nações Unidas, No. 14261, Ala A-1, 12º andar, sala 09, Postal Code (CEP): 04794-000 E-mail: dpo@copersucar.com.br

We hope you make the most of Copersucar!

COPERSUCAR S.A., a company duly constituted with its principal place of business at Avenida das Nações Unidas, No. 14261, Wing A-1, 12^th floor, room 09, Postal Code: 04794-000, enrolled with the National Corporate Taxpayers Register of the Ministry of Finance (CNPJ/ME) under number 10.265.949/0001-77 (“Copersucar”), under this Personal Data Privacy Policy (“Privacy Policy” or “Policy”) makes a commitment to the security and protection of Personal Data (as defined below), complying at all times with the legislation covering information security, privacy and protection of Personal Data observing, to the extent applicable, the Brazilian General Data Protection Law, the Brazilian Civil Rights Framework for the Internet and other related legislation.

In addition, this Policy aims to inform the owners about how Copersucar collects, uses, shares and protects Personal Data.

This Policy comes into effect on November 26, 2020.

Introduction

Copersucar is a global exporter of sugar and ethanol using integrated logistics throughout its entire business chain, operational excellence and the sustainable creation of value.

I – Which Personal Data is collected and for what purpose is it treated?

Copersucar treats Personal Data, understood to be data that enable an individual to be identified or to become identifiable (“Personal Data” or “Data”).

Copersucar collects and treats Data on its various interfaces in the normal course of its business.

Thus, it collects the Personal Data of employees, customer representatives, partners, service providers, and suppliers etc. The list of data collected may include: Identification data, contact data, browsing data (cookies, IP addresses), geolocalization, devices, health data (this is considered sensitive Personal Data), biometric data and other data required from time to time for undertaking transactions under Copersucar’s responsibility. The list of data collected may vary according to the relationship existing between Copersucar and the owners.

II – Method and duration of the treatment

Most of the Personal Data that Copersucar processes provided directly by the owners for one of the following reasons:

• Making contact in the course of some business relationship (customers’ representatives, partners and suppliers);
• Secure browsing on our sites and applications;
• Filling out some registration form at Copersucar;
• So that we can provide our services, receive and make payments and provide assistance; and/or
• In their relationships with the employees to defend those employees’ interests and/or fulfill contracts.

,

All Personal Data collected is treated and stored for as long as necessary for complying with the purposes described in this Policy, as well as complying with the legal or regulatory obligations, also bearing in mind the occasional need to use it in legal, administrative or arbitration proceedings.

This, therefore, justifies the retention of Personal Data on our bases, under the same security and protection mechanisms employed in the case of Copersucar information.

III – Parent Company Contact Information

Additional Information, doubts or requests about this Policy can be clarified by the party in charge of protecting Personal Data, using the form available at e-mail address: https://privacy-central.securiti.ai/#/dsr/a176f0d7-3d78-443e-926c-4c304bd8618d or by sending an e-mail to dpo@copersucar.com.br, or a letter to the following address: Avenida das Nações Unidas, No. 14261, Wing A-1, 12^th floor, room 09, Postal Code: 04794-000 (care of Copersucar S.A.).

The party responsible for Copersucar is Certsys Tecnologia da Informação Ltda, a duly constituted company with its principal place of business at Rua Doutor Rafael de Barros, 209, Suite 132, Paraíso, São Paulo/SP Postal Code, enrolled with National Corporate Taxpayers Register (CNPJ) under no. 08.821.745/0001-23.

IV – Information about the shared use of data by the parent company and the purpose

Copersucar can share Personal Data with its subsidiary companies and suppliers, if necessary, when conducting its operations and/or meeting its obligations. This sharing involves establishing the parties’ rights and duties, so as to prevent Personal Data being used in a manner other than that stipulated by Copersucar and/or that violates the applicable privacy legislation.

In certain circumstances, at all times with due regard for prevailing legislation, Copersucar may be legally obligated to share Personal Data in response issues raised or legitimate requests.

V – Responsibility of the agents responsible for treatment

In treating Personal Data, Copersucar implements security measures considered sufficient for protecting it, such as:

• Access to the data base restricted to the companies and authorized professionals. • Monitoring the accesses to Copersucar’s internal systems. • Adoption of preventive procedures against information security incidents, as well as remediation and crisis management techniques.

Copersucar makes an effort to protect the Personal Data it handles, but there is no guarantee that this data is immune to improper access by unscrupulous persons.

Copersucar is not accountable for acts by third parties other than its traders or employees going about their work.

When accessing the Copersucar web site where there are fields for user login and password, the user is responsible for keeping their passwords and logins confidential. Copersucar is entitled to assume that aby person accessing the site using a login and password attributed to a user has the right to do so. Usually will be totally responsible for the activities of any person accessing the site using a password attributed to them, even if that person is not in fact authorized to do so by the user. Whenever there is reason to suspect that their password is being used without authorization, the user should change the password immediately.

In this respect, users are recommended to take the necessary precautions surrounding the confidentiality of their Personal Data when using the site and the internet as a whole.

The function of the user’s password is to protect their account against it being used by third parties and, therefore, Copersucar always suggests: (i) that users use strong passwords that are solely for accessing the digital environments of Copersucar, (ii) that this password is never shared with third parties, limiting access to their computer and browser, and (iii) that users log off from their accounts after using the services.

VI – Owner’s rights

The owner of the Personal Data enjoys the following rights in regard to their data, insofar as those rights are recognized under the applicable laws:

• Confirmation of the existence of treatment: confirmation of the of treatment of the data held by Copersucar;
• Access to the data: access to the data collected by Copersucar, with the exception of cases protection of commercial and industrial secrets;
• Correcting data: requests to correct data that is incomplete, out of date our incorrect;
• Anonymizing, blocking or eliminating: anonymizing, blocking or eliminating data that is unnecessary, excessive or treated in a manner that does not comply with applicable legislation provisions. Anonymization will take place bearing in mind the use of reasonable technical methods available when the data is being treated;
• Portability: portability of Personal Data under an express request, according to the regulations of the national authority, with due regard for commercial and industrial secrets.
• Elimination of data: elimination of Personal Data treated with the owner’s consent, except in those cases provided for in the prevailing legislation; in this regard, subject to local legal requirements, Copersucar can retain the Personal Data in case: (i) it is legally obligated to keep it, (ii) to comply with the and/or regulations that so stipulate; (iii) it needs the Data to submit, exercise or defend legal claims; and (iii) [sic] it needs to retain control of the Data for public health reasons.
• Information about data sharing: receiving notification about Personal Data shared with public and private entities.
• Revocation of consent: revocation, at any time, of the consent given against the owner’s express request. The revocation procedure will always be free of charge and facilitated;

It is possible to exercise these rights by contacting us by sending a request to the following address: dpo@copersucar.com.br

VII – Data of Minors

We do not deliberately collect Personal Data of children under the age of 13 (thirteen) years or those under the applicable age limit (“Age Limit”). If you are under the Age Limit, do not use the Copersucar services and do not provide any Personal Data.
If you are the parent of a minor and you discover that your child has provided Personal Data to Copersucar, contact us using the available at the e-mail address or via the e-mail account dpo@copersucar.com.br.

If we become aware that we have collected the Personal Data of someone under the age of 13 (thirteen), we will take reasonable measures to remove their Personal Data.

VIII – Contact information

In case of any additional doubts, please e-mail us at: dpo@copersucar.com.br.

IX – Amendments to this Policy

We may occasionally amend this Policy. When we make material changes to this Policy, you will be duly notified, according to the circumstances, for example, by displaying a notice on the main page of https://www.copersucar.com.br or by sending an e-mail to contacts registered in our services.

X – Final provisions

Copersucar, at its sole discretion, may modify the terms and conditions in this Notice, including, but not limited to, situations arising from compliance with legislation, alterations to the products and services, or by the rollout of new technological tools. For greater security and within the principle of transparency, any updates to the Privacy Notice will be made known to the owners on the Copersucar site (www.copersucar.com.br). Copersucar takes no responsibility for problems arising from delays, interruptions or blockages in the transmission of information sent to its e-mail address.

This Policy was last updated on November 26, 2020.